Fintech 2026

ARGENTINA Law and Practice Contributed by: Santiago J. Mora, Nicolas Garfunkel, Milagros Caneda and May Steward, GPG Advisory Partners

10.3 Classification of Blockchain Assets Although Law No 27,739 introduced a definition of AVs, its primary focus is on establishing the regula - tory framework for PSAVs. As a result, while the law provides some clarity on the concept of AVs, there is still no comprehensive regulation specifically govern - ing crypto-assets. In this context, pre-existing rules and generic stand - ards will apply (see 2.2 Regulatory Regime and 2.11 Implications of Additional, Non-Financial Services Regulations ), and the regulatory treatment of crypto- assets in Argentina will depend on their nature, with some being considered marketable securities and therefore subject to the provisions of the CML and CNV Resolutions No 1069, 1081 and 1087 (see 1.1 Evolution of the Fintech Market ). 10.4 Regulation of “Issuers” of Blockchain Assets In Argentina, there is no specific regulation applicable to issuers of blockchain assets in general. Although, as mentioned in 10.3 Classification of Blockchain Assets , where crypto-assets are security tokens that could be assimilated into marketable securities, the issuance of such assets would fall under the provi - sions of the CML, and has been regulated pursuant to CNV Resolutions No 1069, 1081 and 1087 (see 1.1 Evolution of the Fintech Market ). In addition, where the issuer carries out crypto-to-fiat or crypto-to-crypto exchange activities in Argentina, it shall be required to comply with the regulatory frame - work applicable to PSAVs, as established under CNV Resolution No 1058 (see 1.1 Evolution of the Fintech Market and 6.3 Impact of the Emergence of Crypto- currency Exchanges ). 10.5 Regulation of Blockchain Asset Trading Platforms See 6.3 Impact of the Emergence of Cryptocurren- cy Exchanges and 6.6 Rise of Peer-to-Peer Trading Platforms . 10.6 Staking The provision of staking services relating to crypto - currencies is not yet regulated in Argentina. In this context, pre-existing rules and generic standards will

apply (please see 2.2 Regulatory Regime and 2.11 Implications of Additional, Non-Financial Services Regulations ). 10.7 Crypto-Related Lending The provision of lending services relating to cryptocur - rencies has no specific regulation in Argentina. In this context, it can be understood that the general rules of the regime applicable to PNFCs apply. See 2.2 Regu- latory Regime and 4.1 Differences in the Business or Regulation of Fiat Currency Loans Provided to Different Entities . 10.8 Cryptocurrency Derivatives There is no specific regulation yet in Argentina regard - ing cryptocurrency derivatives. In this context, pre- existing rules and generic standards will apply (see 2.2 Regulatory Regime and 2.11 Implications of Addi- tional, Non-Financial Services Regulations ). 10.9 Decentralised Finance (DeFi) Currently, there is no specific regulation for DeFi. In this context, pre-existing rules and generic stand - ards will apply (see 2.2 Regulatory Regime and 2.11 Implications of Additional, Non-Financial Services Regulations ). 10.10 Regulation of Funds In 2023, Banco Industrial (BIND) launched the first investment fund that includes investments in digital assets alongside instruments regulated by the CNV. The investment portfolio includes Bitcoin futures, and Argentine Depositary Certificates of Foreign Shares in tech companies and in fixed income assets. This initiative was later followed by similar developments from other market participants. In addition, in recent months, the CNV issued Reso - lutions No 1069, 1081 and 1087, which authorised the tokenisation of certain securities, including units of closed-end investment funds with public offering backed by RWAs (see 1.1 Evolution of the Fintech Market ). 10.11 Virtual Currencies Under Argentina’s Law No 27,739, virtual currencies are broadly encompassed within the category of “vir - tual assets”.

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